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OMB Circular A-133 Immunization Compliance Supplement

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4. 4 OMB Circular A-133 A-133 internal control provisions require auditors to plan and perform “testing of internal control … relevant to compliance requirements for each major program.”
Major programs are determined using a four-step approach described in OMB Circular A-133, §.520.
Not all major programs need to be audited every year, e.g., low-risk major program.

5. 5 Immunization Compliance Supplement Sets forth internal control audit requirements for major programs as defined in OMB Circular A-133, §.520.
Changes reviewed/approved through ISD, PGO, HHS, and OMB.
Consists of four sections:
I Program Objectives
II Program Procedures
III Compliance Requirements
IV Other Information
Minor (non-substantive) changes to sections I and II. Significant changes to section III, sub-section N. Special Test and Provisions; and to section IV.

9. 9 Challenges Revisited Complying with the “old” immunization compliance supplement was difficult under “new” operating procedures for funds management and centralized vaccine distribution.
Most issues addressed by updating section IV of the compliance supplement.
Some of the resolved issues included:
With DA vaccine no longer obligated to grantees, should DA vaccine be included as part of the value of vaccine received? If yes, where would auditors/grantees get value of vaccine received data?
Are vaccinating providers (LHDs and private providers) considered subrecipients? If yes, how would the provisions of A-133 apply given centralized vaccine distribution. If no, how would auditors/grantees account for vaccine shipped directly to vaccinating providers?
Should the value of DA vaccine shipped directly to vaccinating providers be included as a grant expenditure for purposes of determining audit coverage as a major program?
Should the value of DA vaccine shipped directly to vaccinating providers be included in the Schedule of Expenditures of Federal Awards (SEFA)?